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issued on July 9, 1993. Following this remand, the parties filed
with the Court on November 2, 1994, stipulated computations (the
1994 computations) covering the years 1976 to 1979. The 1994
computations did not include the amounts of the 1979 ITC that
were included in the 1992 computations. This Court's decision,
based on the 1994 computations, was entered on November 17, 1994,
and became final within the meaning of section 7481(a)2 on
December 17, 1994 (the 1994 decision). As part of that decision,
it was decided that there was an overpayment for the taxable year
1977 in the amount of $9,089,070.00, and a deficiency for the
taxable year 1978 in the amount of $1,544,492.72. The decision
document indicated that it "[incorporated] herein the facts
recited in the respondent's computation as the findings of the
Court".
Petitioner's tax liability for the taxable years at issue,
with the effect and timing of various credit and net operating
loss (NOL) carrybacks, reflecting the 1994 decision, is described
in more detail as follows:
1977 Tax Year
Petitioner had a tax liability for the 1977 tax year of
$24,200,118, before taking into account any credit carrybacks.
Between April 15, 1977, and June 17, 1978, petitioner made
2 That section provides for a 30-day instead of a 90-day
period for a decision of this Court to become final where there
has been a remand by the Court of Appeals.
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